it was held in An Informer v A Chief Constable [2012] EWCA Civ 197 that while the police did not owe a duty of care to an informer in respect of pure economic loss, they would owe him a duty in respect of his physical safety. The Court of Appeal considered that the relationship between the police and the informer was a confidential one, and the police owed an informer a duty of care to protect him from risks to his physical safety and wellbeing to which he was potentially exposed as a result of his activities in providing information about others.